Privacy Policy

Effective date: 2022-08-12

 

Preamble Ramble

THIS PRIVACY POLICY IS DRAFTED FOR PURPOSTRY’S UNIQUE COMBINATION OF PRODUCTS, AND THAT ITS HOLDING COMPANY IS INCORPORATED IN SINGAPORE.

YOU MIGHT BE TEMPTED TO COPY THIS POLICY THINKING THAT TIMOTHY LOW USED TO BE A CORPORATE LAWYER. BESIDES THAT BEING AN INFRINGEMENT OF COPYRIGHT, THIS PRIVACY POLICY PROBABLY WILL NOT BE SUITABLE FOR YOUR BUSINESS.

 

Privacy Policy Starts Here...  

 

BACKGROUND INFORMATION

We value your privacy. 

 

This Privacy Policy (“Privacy Policy”) forms part of the legally binding Agreement that you enter into with us when you visit, view, access or otherwise use any Content, including without limitation this Website, or any Product.

 

PARTIES

“You”, “your” or any other related word refers to any person who visits, views, accesses, or otherwise uses the Content, including without limitation this Website.

 

Digimax Life Pte Ltd is a company incorporated in Singapore, that operates this website, Purpostry.com, including all related subdomains (“Website”), and provides Content. (“Company”, “we”, “us”, or “our”)

 

AGREEMENT (INCLUDING THIS PRIVACY POLICY)

This Privacy Policy explains how and why we collect, use, store and share your Personal Data, your rights regarding your Personal Data and how you can contact us if you have any questions or complaints. 

 

“Content” is information you receive through the Website, Products, and other forms of communication, including without limitation all of the various means we use to communicate with you, including via this Website, videos, podcasts, presentations, email, phone, social media, Products or otherwise. 

 

“Personal Data” refers to data that we collect, that may directly or indirectly, identify, describe, relate to or be associated with you.  This Privacy Policy applies to Personal Data we collect when you interact with us, including without limitation, by visiting and using our website.   For the avoidance of doubt, this Privacy Policy only applies to your Personal Data that is collected by us through your interactions with us via our website, and Products.  We do not, and cannot control the privacy practices of websites and services that do not belong to us.

 

“Products” are free or paid Content in the form of programs, courses, coaching, presentations, webinars, classes, ebooks and other products or services provided by us.  Products are a type of Content, and may comprise Content.

 

The Content is offered or provided subject to the terms and conditions in this Privacy Policy.  For the avoidance of doubt, this Privacy Policy form an integral part of the Agreement. 

 

By visiting, viewing, accessing or otherwise using the Content, you agree to be bound by this Privacy Policy, the Terms & Conditions and the Disclaimer, which are hereby incorporated by reference (collectively, “Agreement”). 

 

If you do not agree and accept the terms and conditions of the Agreement (including this Privacy Policy), you are required to leave this website immediately, and cease using the Content, even if you have paid for it.

 

We may amend the Agreement (including this Privacy Policy) from time to time without reference to you. Amendments have immediate effect upon publication on the website. You are solely responsible for keeping abreast of updates, as your continued use of the website and Products after any amendment the Agreement will constitute your acceptance and agreement to continue to be bound by the latest Agreement, including any and all amendments.

 

PART A – WHAT, HOW, WHY & WHO

 

WHAT INFORMATION WE COLLECT &

HOW WE COLLECT IT

 

Personal Data Provided By You:

We collect Personal Data that you provide to us, and may include information provided when (a) request Products or Content, (b) sign up to receive Content via email, messenger, web-push notifications, or any other format (c) subscribe to any Content, (d) comment on any posts or otherwise communicate with us on any social media platform, (e) register for presentations or classes, (f) fill out any forms, (g) access public or private membership groups, including those hosted via a third-party platform (for instance, on Facebook), (h) sign up to become our affiliate partner, (i) respond to any survey, (j) participate in any contest or sweepstakes, or (k) contact us through any other means, including via an online form, phone call, or email (each an “Act”, any combination are “Acts”). 

 

Examples include your first name, last name, telephone number, email address, shipping address, billing address, physical address (such as your address, state, province, ZIP/postal code and city), date of birth, gender, account name, billing information (such as your credit card number), financial information, Social Security Number, Tax Identification Number, Employer Identification Number, PayPal address, social media information, and other information you provide to us through survey responses, feedback, reviews and other means of communication.

 

Automatically Collected Personal Data:

We also collect Personal Data automatically, for instance, when you visit or use our Website or open or respond to our emails.  This might happen when you visit any page that displays Content, provide information to our service providers or purchase or return a Product, open or respond to emails, select the ways in which we may communicate with you, etc.

 

We may receive or collect any of the information listed above. We may also collect Personal Data listed in this non-exhaustive list:

Data about your computer or mobile device, including inter alia, your Internet Protocol (“IP”) address, browser software, browser type, browser version, the type of mobile device you are using, the unique mobile device ID, your mobile operating system, web browser software on mobile, cookies from your browser, unique device identifiers, the referring website, the date, time and length of your visit, including the specific pages you visit, information on how you interact with the website, Products and tools and other diagnostic data.

 

Personal Data Collected Through Or From Third Parties: 

When you comment on, “like” or “dislike” our posts, or otherwise interact with us on any social media platform, or when you access public or private membership groups hosted on a third party platform (for example, Facebook), we may collect Personal Data, including inter alia, your profile information, profile picture, social media information, social media handles or nicknames, name, purchase history, email address, device identifiers and demographic information.

 

WHY WE COLLECT PERSONAL DATA

We collect your Personal Data for business and commercial use, including to (a) register or grant you access to a Product, (b) register or grant you access to a public or private membership group or other account, and maintain and service your profiles for such accounts, (c) validate and authenticate your profile when logging into a public or private membership group or other account or when accessing or purchasing a Product, (d) analyze interactions with you to improve quality, (e) identify your product preferences and shopping preferences, (f) secure our website and data, (g) create Products that you may be interested in, (g) ship or otherwise deliver, process payment for, communicate about, and track orders of any Products, (h) suggest Products you may like based on past purchases and otherwise personalize your experience with the website, (i) provide promotional and marketing communications and information if you elect to receive it, including email marketing, (j) improve the design, functionality and ease-of-use of our website and Products, (k) respond to any inquiries, reviews or other feedback you submit to us, (l) provide customer service, (m) conduct research to improve our business processes, (n) administer affiliate programs, (o) administer contests, sweepstakes, surveys or promotions, (p) administer any business needs related to your purchase of any Products, (q) detect security incidents and protect against, stop, resolve and prevent any fraud and fraudulent transactions and any malicious, deceptive or illegal activity, (r) comply with all applicable law, and/or (s) respond to legal and regulatory inquiries and assist law enforcement.

 

WHO WE SHARE PERSONAL DATA WITH

We may share your Personal Data with parties with whom we do business or intend to do business, including without limitation, (a) affiliate partners, (b) business associates (third parties we work or intend to work with to create or offer a product, service or promotion), (c) service providers including without limitation (i) analytics providers, (ii) cloud service providers, (iii) customer analysis providers (such as to analyze visitors clicks and navigation around the website, (iv) customer service providers, (v) delivery and fulfillment service providers, (vi) email, marketing and advertising technology and service providers (including without limitation email marketing and campaign providers, marketing software providers, direct mail providers, marketing analytics providers and sales funnel providers, in order to communicate with you, including without limitation, sending you emails, newsletters, promotional materials, marketing materials or other information), (vii) fraud prevention service providers,(viii) payment processors (to collect and process payment for any Products you purchase), (ix) professional service providers (such as auditors, consultants, lawyers, and other professionals who rely on the data to provide us with professional services), (x) technology service providers, (d) government agencies (including without limitation any statutory body, agency, courts, regulators and law enforcement in the event we are required to comply with applicable laws and regulations or a legally binding process, or in response to subpoenas, warrants, government inquiries or investigations, and court orders; in order to (i) establish, exercise, protect or enforce our legal rights and the legal rights of our agents, employees and affiliates, (ii) defend against a legal claim, (iii) protect you, us or third parties against injury, interference, fraud or harm or (iv) take action related to violations of our policies, including this Privacy Policy and our Terms & Conditions, or potentially illegal activities, (e) any public forum (when you leave a post, comment or review, even on our website or communicate with us in any other way, that information may be on a public forum, and will be available to the public and we may elect to share your post, comment or review outside of the website) (f) social media platforms (note that your Personal Data shared with social media platforms are not governed by this Privacy Policy).

 

WE WILL NOT SELL YOUR PERSONAL DATA

We value your privacy, and we will not sell, rent or trade your Personal Data with or to any third parties.  We also do not “sell” your Personal Data as defined by the California Consumer Privacy Act or the Nevada Privacy Law.

 

In the event that we or any part of our Company or business of the Company are acquired by a third party as a result of a transfer, sale, merger, acquisition, reorganization, liquidation, consolidation, merger or sale of some or all of our Company, your Personal Data may be a transferred as an asset.  We may also share Personal Data to prospective purchasers for conduct of diligence.

 

PART B – YOU HAVE THE POWER

 

TRACKING TECHNOLOGIES SUCH AS COOKIES

We and our service providers may collect and access your Internet Protocol (IP) address, browsing metadata and other numerical identifiers, such as your browser type, version and operating system (collectively, “Browsing Data”), and/or use, place, collect and store, cookies, web beacons, remarketing pixel tags, or other similar tracking technologies.  These may be used to, including without limitation, improve and personalize your user experience, understand how you use the website, provide tailored ads, analyze trends, data, and website performance, administer the website, identify and track you when you use different devices, determine if you are logged onto the website, provide security and provide a range of features, customization and functionality. 

 

By visiting or using the website without opting out of cookies, you consent to the use of Browsing Data, cookies and other tracking technologies as described in this Privacy Policy.  We have no control over third party service providers and their use of such tracking technologies, their privacy policies and practices. Please visit their websites to learn about their privacy policies.

 

YOUR PERSONAL DATA, YOUR CHOICE

 

You may block or “opt out” of cookies. 

Browsers, while often accepting cookies as a default, give you the choice to prevent accepting new cookies, disabling cookies, and/or receiving notifications when you receive new cookies. 

 

NOTE: Disabling cookies may interfere with your user experience, including your ability to use or access Products, make purchases from the website, or receive personalized content.

 

CalOPPA “Do Not Track”. 

In accordance with California Online Privacy Protection Act (CalOPPA), please note that our systems currently do not recognize browser “Do No Track” instructions.

 

What You Can Do Regarding Your Personal Data. 

You can (a) request that we delete your Personal Data, subject to certain exceptions, by contacting us at any time using the contact details in this Privacy Policy; (b) request to see your Personal Data, (c) withdraw consent for our use of your Personal Data, (d) review and request that we rectify or otherwise edit your Personal Data, (e) cancel, restrict, or limit the processing of your Personal Data, and (f) request your Personal Data and transfer it to another controller without any impediments on our part, by contacting us using the contact details in this Privacy Policy. 

 

For clarity, we retain Personal Data for the period required for expedient business operations, or until you ask us to delete your Personal Data. 

 

We store your Personal Data safely

The security of your Personal Data is important to us.  We have taken steps to protect your Personal Data including employing physical, technical and procedural safeguards.  Having said that, no method of transmission over the internet or other network can be 100% secure, therefore we do not guarantee that Personal Data you transmit will remain secure and not be intercepted or misused.  By consenting to this Privacy Policy, you acknowledge that we do not guarantee that your Personal Data will be protected from misuse or interception by third parties.

 

You may unsubscribe from our emails.

When you took an Action (such as requesting or purchasing a Product) and provided us with your email address, you agreed to receive email communications from us, including without limitation, promotional emails and newsletters.  You can opt out at any time by clicking the “unsubscribe” link contained in each email. 

 

Unsubscribing from email marketing may or may not unsubscribe you from other emails we send, for example Products you purchase. THIS MEANS THAT YOU MAY NO LONGER RECEIVE EMAILS FOR PRODUCTS THAT YOU MAY HAVE PURCHASED. This also means that you may continue to receive emails about those Products.  If you do want to stop receiving those emails, please contact us using the contact details in this Privacy Policy. DO NOT USE THE “REPORT SPAM BUTTON/LINK”.

 

You may unsubscribe from other channels of communication.

We may also communicate with you via messenger services (such as Facebook Messenger), Whatsapp, short message service (SMS) messages, via telephone, or even physical mail.  Most of the messenger or message options have unsubscribe links and work similarly to unsubscribing from emails.  If you are unable to locate the unsubscribe link or if there is none, such as with physical mail, you can opt-out by contacting us using the contact details in this Privacy Policy.

 

Personal Data Collected By Third Parties

Some links on our website belong to third parties, such as links to our partners’ websites, or social media platforms.  If you click on a link to a third party website, and you use that third party website, you will be subject to their Privacy Policy, if any. 

 

You may consider reviewing their privacy policies to ensure that you agree with them, as we do not control their privacy policies.

 

 

PART III – SPECIFIC LAWS, ETC

 

HANDLING PERSONAL DATA ACROSS BORDERS

THE PERSONAL DATA PROTECTION ACT OF SINGAPORE

We are a company incorporated in Singapore.  Personal Data is protected by Singapore’s Personal Data Protection Act (PDPA). Our servers and our service providers and their data centres may be located in many locations around the world.  As a result, some of your Personal Data may be collected, used, transferred, maintained, disclosed and stored outside of your jurisdiction.  By accessing this website, you acknowledge and agree that the collection, use, transfer, maintenance, disclosure and storage of your Personal Data, Browsing Data and communications related to or arising out of your use of this website is governed by the PDPA.  While we have the appropriate safeguards in place, the PDPA may have requirements that differ from those in your jurisdiction.

 

CALIFORNIA CONSUMER PROTECTION ACT (“CCPA”)

This section applies to residents of California.  Accordingly, references to “you” and “your” in this section refer to residents of California only. 

 

As a California resident, you have a right to know the following:

 

Information on what Personal Data, sources, use, storage and sharing, can be found in this Privacy Policy under the heading “What We Collect & How We Collect It”.

 

Information on the business or commercial reasons for collecting Personal Data, can be found in this Privacy Policy under the heading “Why We Collect Personal Data”.

 

Information on which third parties we share Personal Data with can be found in this Privacy Policy under the heading “Who We Share Personal Data With”.

As a California resident, you have certain rights you can exercise.  We provide a sampling for your convenience, and do not warrant its accuracy or completeness, and should not be relied on.

• You have the right to procure specific information pertaining to our collection of your Personal Data in the past 12 months.
• You have the right, subject to certain exceptions, to procure that we delete your Personal Data.
• You have the right to not be discriminated against for exercising your rights under the CCPA.

To exercise any of your rights, please contact us using the contact details provided in this Privacy Policy, providing proof of your California residence.

 

 

NEVADA PRIVACY LAW

This section applies to persons protected by the Nevada Privacy Law.  Accordingly, references to “you” and “your” in this section refer to such persons only. 

 

You have certain rights under the Nevada Privacy Law.  We provide a sampling for your convenience, and do not warrant its accuracy or completeness, and should not be relied on.

You have the right, subject to certain exceptions, to procure that we delete your Personal Data.  Please contact us using the contact details provided in this Privacy Policy, providing proof of your Nevada residence. 

You have the right to request that we do not sell your Personal Data.  We value your privacy, and do not sell any Personal Data.  Accordingly there is no need for you to give us “do not sell” instructions. 

 

GENERAL DATA PROTECTION REGULATION (GDPR)

This section applies to persons protected by the GDPR. Accordingly, references to “you” and “your” in this section refer to such persons only. 

 

In this section, “Personal Data” refers to personal information which can directly or indirectly identify such individual, such as a person’s first name and last name, email address, ethnicity, gender, etc.

 

You have certain rights under the GDPR.  We provide a sampling for your convenience, and do not warrant its accuracy or completeness, and should not be relied on.

 

• You have the right to know if your Personal Data is being processed, and details as to the collection, processing, storage and sharing of the Personal Data
• You have the right to correct or complete Personal Data about yourself that is inaccurate by providing the relevant information.
• You have the right, under certain circumstances, to request that we delete your Personal Data.
• You have the right to limit the processing of your Personal Data
• You have the right to receive information about cross border transfers of your Personal Data, which information can be found in this Privacy Policy under the heading “Handling Personal Data Across Borders & PDPA”.

 

To exercise any of your rights, please contact us using the contact details provided in this Privacy Policy with proof that you are a person protected by the GDPR. 

 

COMPLIANCE WITH LAWS

This website intended for person above the age of 21 from Singapore.  If you are not over 21 years old, you are not permitted to access or otherwise use this website or perform any of the Acts. 

 

We do not intentionally collect, use, store or share Personal Data from persons under 21 years old.  If you know or have reason to believe that we have such data, please contact us using the contact details provided in this Privacy Policy for removal of that Personal Data.

 

CONTACTING US

If you have any questions or complaints related to this Privacy Policy, or would like to exercise any of your rights, please contact our Data Protection Officer by email at [email protected]